A Modern Slavery Policy and Supplier Code of Conduct, linked to a Whistleblower Protection Policy. Our Modern Slavery Policy and Supplier Code of Conduct each specifically address our commitment to be vigilant on modern slavery issues, while the Whistleblower Policy strongly encourages employees and other stakeholders to report all violations of policies and ensures there will be no negative repercussions for doing so.
Our Supplier Code of Conduct contains robust modern slavery contract warranties and covenants from suppliers. It includes recommendations that our suppliers “push” these same warranties and covenants up the supply chain by including them in their procurement contracts with their respective suppliers (our second-tier suppliers). A plan is in place to raise awareness of our Supplier Code of Conduct as part of the onboarding process for all new suppliers and new contract awards.
Mapping of and assigning a risk rating to key first-tier suppliers in our supply chain based on perceived country level risk, business sector and industry risk, specific product and/or services risk and spend level.
Targeted, customised “due diligence” of suppliers identified as being at highest risk for potential modern slavery incidents pursuant to item 3 above or otherwise. The due diligence surveys are designed to help validate and further assess the potential modern slavery risk of each supplier, by rating their modern slavery risk profile as High, Medium, or Low based on their responses to a series of questions relating to (i) their own operations and (ii) their supply chain. Due diligence responses are evaluated to determine whether and to what extent any additional follow up might be required, sensible and feasible in the circumstances, after which an action plan is meant to be created to implement such follow up in each relevant case.
Site visits of existing and prospective suppliers to witness firsthand supplier policies and practices.
We continued and further entrenched implementation of the Modern Slavery Risk Mitigation Program.
Those suppliers who did not respond to our due diligence inquiries will continue to be actively pursued until they complete a survey.
Previously, we added language supporting the modern slavery response in our new award contracts. We have now also updated our tender document to raise awareness at the start of the tendering process.
We secured contracted services and software to enable onboarding of new suppliers including them in the Modern Slavery Risk Mitigation Program.
We travelled to one of our higher risk sourcing regions and visited 5 existing and prospective supplier sites (not previously part of the due diligence inquiries). We reviewed their business including size, references, suppliers, market, and policies. We also assessed their modern slavery awareness, supporting labour structure, and quality practices. Based on the site visits, we chose not to continue with one supplier as they were unlikely to comply with our Modern Slavery Risk Mitigation Program.